State Court Stipulation and Proposed Order (General Civil) - Iowa

Iowa Civil Stipulation and Proposed Order

Before you use this: Complete only the terms the parties actually agree to. A written discovery-procedure stipulation under Iowa R. Civ. P. 1.506 is subject to a contrary court order. An agreement does not itself change a court-ordered schedule; request leave and show good cause under rule 1.602(2)(c). Submit the proposed order separately in an editable Word-compatible format under Iowa R. Elec. P. 16.311(2) and 16.409.

Stipulation

Date: [__/__/____]

Stipulating parties: [NAMES AND ROLES]. Other parties, if any: [NAMES AND ROLES / NONE].

The stipulating parties agree to the terms below and, where a court order is requested, jointly ask the court to enter the proposed order. They identify the existing order, deadline, or claim affected by each term so the requested relief can be applied to this case.

1. Existing case schedule and matter addressed

Relevant existing order and date: [IDENTIFY ORDER AND DATE / NONE].

Parties or claims affected: [SPECIFY]. Unaffected terms: [SPECIFY OR NONE].

2. Agreed terms

1. [STATE THE FIRST AGREED TERM, INCLUDING WHO MUST ACT AND WHEN.]
2. [STATE THE SECOND AGREED TERM OR DELETE.]
3. [STATE ANY CONDITION, NOTICE, OR DOCUMENT EXCHANGE OR DELETE.]

Discovery procedure, if applicable: The parties agree in writing to [DESCRIBE THE DEPOSITION OR OTHER DISCOVERY PROCEDURE]. This term is made under Iowa R. Civ. P. 1.506 and remains subject to a contrary court order. If it also changes a court-ordered deadline, the parties request leave under rule 1.602(2)(c).

Expert disclosure deadline, if applicable: [EXISTING DATE] becomes [PROPOSED DATE] only upon court approval if the date is in a scheduling order. Iowa R. Civ. P. 1.500(2) governs the disclosure itself.

Claim dismissal, if applicable: [HOLDER OF CLAIM] requests dismissal of [IDENTIFY OWN PETITION, COUNTERCLAIM, CROSS-CLAIM, CROSS-PETITION, OR INTERVENTION PETITION] ☐ with prejudice ☐ without prejudice. State the scheduled trial date, any counterclaim against the dismissing party, and why court consent or other-party consent is or is not needed under Iowa R. Civ. P. 1.943: [FACTS]. Delete this paragraph if no claim is being dismissed.

3. Basis for court action, if requested

Order requested: [STATE PRECISE RELIEF]. Rule or existing order governing it: [IDENTIFY].

Good cause for any scheduling-order change: [FACTS EXPLAINING WHY THE EXISTING SCHEDULE CANNOT REASONABLY BE MET AND WHEN THE BASIS BECAME KNOWN].

Effect on trial, other deadlines, other parties, and prior orders: [EXPLAIN]. If a trial continuance is requested, file the required motion promptly and obtain the represented party's written approval unless waived by the court under Iowa R. Civ. P. 1.910; identify the cause and the parties' agreement for the court under rule 1.911.

Additional facts supporting the requested order: [FACTS / NONE].

No provision of this stipulation takes effect as a change to a court order until the court grants that change. The parties retain all claims and defenses except those expressly disposed of in a filed dismissal or entered order.

4. Signatures

Filing party's mailing address and contact: [ADDRESS; PHONE; EMAIL].

Proposed order — submit separately when court action is requested

The court has considered the stipulation filed on [__/__/____] and [IDENTIFY ANY OTHER FILING].

☐ Good cause has been shown under Iowa R. Civ. P. 1.602(2)(c) to change the scheduling order dated [__/__/____].

☐ Other basis for relief: [STATE THE FINDING AND AUTHORITY].

IT IS ORDERED:

1. [STATE EACH ACTUAL CHANGE OR DIRECTIVE WITH ITS DATE AND RESPONSIBLE PARTY.]
2. [STATE ANY ADDITIONAL DIRECTIVE OR DELETE.]
3. All provisions of the order dated [__/__/____] that are not expressly changed here remain in effect. [DELETE IF INAPPLICABLE.]

Judge's signature: ______________________________ Date: [__/__/____]

Judge's name: [NAME]

Filing and service record

File the stipulation through EDMS when Iowa R. Elec. P. 16.302 applies. Present the proposed order as a separate, editable Word-compatible document, using a font allowed by rule 16.409. Check EDMS's notice to identify who was served under rule 16.315. Serve each person EDMS did not serve by an authorized method; file a certificate of that service promptly under rule 16.316. For an email method outside EDMS, Iowa R. Civ. P. 1.442(2) requires the recipient's written consent in this case specifying the email address.

Document filed or presented: [STIPULATION / PROPOSED ORDER / BOTH]. EDMS filing date: [__/__/____].

EDMS notice identifies these registered filers as served: [NAMES / NONE].

Persons EDMS did not serve: [NAMES / NONE].

Certificate of service for service outside EDMS

I certify that on [__/__/____] I served [IDENTIFY DOCUMENT] on the following persons by the methods listed. [DELETE THIS CERTIFICATE IF EDMS SERVED EVERY PERSON ENTITLED TO SERVICE AND NO OTHER SERVICE WAS REQUIRED.]

Signature of person making service: [SIGNATURE]. Printed name: [NAME]. Date: [__/__/____].

Sources and references

• Iowa Rules of Civil Procedure, current chapter 1
• Iowa Rules of Electronic Procedure, current chapter 16